Feedback for Delegated regulation for carbon removals and carbon farming
The Bioenergy Association of Finland would like to thank for the opportunity to give feedback on the carbon farming methodologies. We appreciate that certain positive adjustments have been introduced to make the methodology more realistic and practically implementable.
In particular, we welcome the clarification that health-related fertilisation is permitted in afforestation projects. This will support improved forest growth and thereby enhance carbon sequestration, including on sites with poorer soil conditions. It also better reflects the diversity of forest management practices across Europe.
However, we deeply regret that the delegated act does not acknowledge the potential of afforestation on peatlands. Both peatland restoration and afforestation can deliver climate benefits, depending on site-specific conditions and time horizons. The European Forest Institute (EFI)’s Carbon Farming in the European Forestry Sector (2024) report1 identifies several measures suitable for also on peatlands. The measures presented in the EFI report have been assessed against the criteria of the CRCF Regulation. Nevertheless, the proposed methodology does not recognise these measures, which risks excluding potentially effective mitigation options.
Regarding the rewetting of drained peatlands, the requirement that activities may not take place on land where the water table has been artificially lowered after 1 January 2023 requires further justification. Newly drained peatlands are known to generate particularly high greenhouse gas emissions, as peat decomposition accelerates immediately after drainage. These areas may therefore offer some of the most significant and immediate climate benefits if restoration or rewetting measures are implemented without delay. It is therefore important to clarify the rationale for selecting this specific cut-off date and to assess whether it is environmentally well justified.
The draft states that the first re-certification audit may take place within four years if the absence of a methane emission peak can be demonstrated. However, the procedures or criteria for such demonstration are not defined. It should be clarified whether verification is based on direct measurements, modelling, expert judgement, or a combination thereof, and what kind of evidence is considered adequate. Also, when requiring either extensive measurements or substantial background information for modelling, it must be noted that sufficient highresolution data is not available for many peatland types. Additionally, the IPCC coefficients are highly aggregated and intended for national or broad regional assessments, making them unsuitable for plotlevel calculations. This may lead either to excessive measurement requirements or to significant uncertainty in the results.
It is both justified and necessary that carbon credits be based on transparent and credible certification and verification procedures. At the same time, it is essential to ensure that administrative and audit requirements do not become disproportionately burdensome. Excessive administrative demands could reduce the economic viability of projects and discourage landowners from participating.
Lisätiedot:
Toimitusjohtaja Harri Laurikka, puh. +358 40 1630 465, harri.laurikka@bioenergia.fi